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Mr. Allen S. Weaver -2- June 17, 1994 Energy Fuels Mining Company cleanings used to be disposed in the refuse pile and now won't be. One place to consider disposing of these cleanings is the area just east of the pond and west of the refuse pile. Another place might be where Topsoil Pile No. 3 used to be. Please address this item. 4. On page 482R of EFMC's March 1994 submittal, it is stated in the last paragraph on that page that "In addition to the sediment pond, the permanent diversion of Starkville Gulch ~III~~ ~~ and associated culverts, and Refuse Collection Ditch 1 will remain. All of these I structures are designed to control runoff from the 100-year, 24-hour storm event. All other drainage and sediment control structures will be removed" (emphasis added). Please note that upland diversion ditches above coal refuse piles are permanent structures. As such, Diversion Ditch Nos. 1 and 2 cannot be approved for removal. Because removing Diversion Ditch Nos. 3 and 4 will cause previously diverted runoff to report to the sediment pond, and because EFMC has requested that pond designs be made an issue separate from this technical revision, the Division cannot approve removal of Diversion Ditch Nos. 3 and 4 at this time as well. Diversion Ditch No. 5 may be removed upon approval of a demonstration that (1) the runoff leaving the area reclaimed below Ditch No. 5, which in the demonstration should include the runoff from above Ditch No. 5 flowing over the reclaimed area, meets the effluent limitation of Rule 4.05.2 and the applicable State and Federal water quality requirements for downstream receiving waters (Rule 4.05.2(3)), and (2) the diversion is no longer necessary to minimize erosion (Rule 4.05.3(1)). As EFMC has requested that pond designs be made a separate issue, and as removal of diversion ditches may affect pond designs, Item No. 19 from the Division's April adequacy review letter is removed from consideration at this time. .-. 5., Item No. 23 of the Division's April adequacy letter regarding disposal of non-coal waste ' °- was discussed in the context of the review of this TR insomuch as a discussion in the F ~'~- ~^i permit application of the final disposal of non-coal waste is required pursuant to ~' '~ Rule 4.1 1.4(2). At this time, the Raton Creek Mine permit application does not contain a section addressing this rule and, as such, the permit application is regulatorily deficient. The Division believes that approval of a submittal regarding non-coal waste is unnecessary for the approval of this TR; however, this item is a permit defect that must be addressed soon. The Division agrees to remove Item No. 23 from its April adequacy letter, with the condition that EFMC submit by August 1, 1994 a plan in accordance with Rule 4.11.4 addressing temporary and permanent disposal of its non-coal waste. 6. Item No. 14 from the Division's April adequacy review addressed the need for a I~ are discussion of the effects of underground mine subsidence on surface facilities. This is ~ (' I - required pursuant to Rule 2.05.616). For the purposes of this TR, the Division believes it is important that Items 14(d), 14(e) and 14(f) are addressed now with respect to the refuse pile. Our primary concern is whether any potential subsidence might affect the stability of the refuse pile and, if the potential for these effects exists, to discuss a subsidence monitoring program for the refuse pile now.